Last Week in Federal Appeals (No. 68)
Last Week in Federal Appeals (No. 68)
Appellate decisions from the week of February 19, 2024
“Once there has been an acquittal, our cases prohibit any speculation about the reasons for a jury’s verdict—even when there are specific jury findings that provide a factual basis for such speculation. . . We simply cannot know why the jury in McElrath’s case acted as it did, and the Double Jeopardy Clause forbids us to guess.”
Justice Jackson, McElrath v. Georgia
Decision Summaries
Supreme Court of the United States
Great Lakes Ins. SE v. Raiders Retreat Realty Co.
The Supreme Court unanimously held that choice-of-law provisions in maritime contracts are presumptively enforceable under federal maritime law. The Court declined to recognize a new exception to presumptive enforceability of choice-of-law clauses for situations where enforcing the law of the State designated by the contract would contravene the public policy of the State with the greatest interest in the dispute.
McElrath v. Georgia
The Supreme Court unanimously held that the jury’s verdict of not guilty by reason of insanity, even where inconsistent with the jury’s other findings as to the defendant’s mental state, constituted an acquittal for double jeopardy purposes. The Court reversed the Supreme Court of Georgia’s order vacating the “repugnant” not guilty verdict alongside the jury’s findings of “guilty but mentally ill” for other charged crimes.
Third Circuit
Mohr v. Trustees of the University of Pennsylvania
The Third Circuit held that the Health Information Technology for Economic and Clinical Health Act, which encourages healthcare providers to adopt and use health information technology, does not cause otherwise private entities to act as agents of the federal government for the purposes of federal jurisdiction.
Fourth Circuit
Doe v. Sidar
The Fourth Circuit held that the lower court erred by understating the plaintiff’s interest in anonymity in her suit against a man for sexually assaulting her. The panel rejected the district court’s holding that fairness considerations invariably cut against allowing a plaintiff to be anonymous without allowing the defendant to be anonymous.
Seventh Circuit
United States v. Williams
On its sixth review of the criminal defendant’s sentence, the Seventh Circuit vacated the district court’s denial of the defendant’s motion to reduce his sentence. The panel held that this case required a more complete explanation of the court’s decision.
Ninth Circuit
Valley Hospital Medical Center, Inc. v. National Labor Relations Board
The Ninth Circuit held that the National Labor Relations Board was not bound by its prior decision where the Ninth Circuit remanded the Board’s prior decision with the direction to supplement its original reasoning. Thus, the panel affirmed the Board’s subsequent decision, which changed its determination that the defendant engaged in unfair labor practices.
Tenth Circuit
Hoskins v. Withers
The Tenth Circuit held that it was not clearly established law that it was retaliatory or excessive force for a police officer to point his gun at a plaintiff when the plaintiff became angry during a traffic stop. The panel further determined that the police officer’s use of force was lawful, and that there was probable cause to search the vehicle and arrest the driver upon the discovery of a large amount of cash.
United States v. Garcia Rodriguez
The Tenth Circuit held that a reasonable jury could not find the defendant guilty of drug possession where she was the passenger of a car containing secret compartments and there was no evidence that the driver had told the defendant about the drugs contained therein or that the defendant had detected the secret compartments.
Any opinions expressed here are our own. This article is not legal advice; if you have a legal issue, you should consult an attorney.
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